MSDS

Limited Quantity Exception Summary
49 CFR 173.306(g), Special Permits SP-14700 and 14818, and CA2009020012 are all Limited Quantity
exceptions for water pump system tanks, for road, rail, and sea transport, issued by the DOT, either on their own behalf
(for domestic transport) or on behalf of the IMO (for international water transport). These provisions allow our water
pump system tanks to be shipped under Ltd Qty exceptions, instead of being treated as a regular HazMat load. For
example:
 The product and package are not
subject to labeling. See 172.400a(b) and 173.306(g).
 The product and package are not
subject to marking (See 172.315(a) and 173.306(g)(2), other than the four
following required marks:
o a test pressure mark on the tank itself,
o either the UN identification number in diamond or the proper shipping name, on the overpack.
o the manufacturer name, city and state, on the overpack.
o The words “Inside containers comply with prescribed regulations,” on the overpack.
 The net product weight is not
stated on the shipping papers. Instead of a weight or volume, only the total number
of tanks (called “cylinders”) is shown, as required by 49CFR 172.202(a)(5)(iii)(B).
 The truck/railcar/container/equipment is not
subject to placarding. See 172.500(b)(3), and the line in 173.306(g)
stating that it is not subject to Subpart F of part 172 (placarding).
 The carrier does not
have to be a HazMat carrier, and the driver does not need HazMat certification. See
173.306(g), the bottom line of the first paragraph, stating that it is not subject to parts 174 or 177, other than the
standard retention of shipping papers.
 The only
carrier requirement is the 375-day retention rule for the shipping papers. See 174.24 and 177.817.
Limited Quantity Exceptions – additional for international seafreight, when shipped above 26 psig
Chapter 7.9 of the International Maritime Organization Dangerous Goods Code (IMDG) allows for the Competent
Authority of an exporting state to issue approvals on behalf of the IMO, and are binding among all countries that
subscribe to the IMO. See the definition of Competent Authority and Competent Authority Approval in 49CFR 107.1.
 In addition to the above points, international ocean shipments do require a HazMat Declaration, and a copy of the
Competent Authority Approval must be included in the shipping papers.
 Contrary to the domestic exception from placarding, international ocean shipments do require a “Limited
Quantities” or “Ltd Qty” placard on the container wherever a class placard is usually required.
Emergency Response Information
Immediate hazards to health If pre-charged as above, these tanks contain either nitrogen or air – non-
flammable, non-poisonous gases. They present no hazard to health.
The risk of transportation danger is immeasurably low, and includes
transportation risks attendant to moving large items plus the remote
possibility of injury from flying or dislodged parts in the event of a
transportation collision.
Risks of fire or explosion Because these tanks contain a pre-charge of air or nitrogen as stated
above, they would not be at special risk of causing a fire or explosion,
but if there were another cause for a fire or explosion, there is a slim
chance that a tank could burst, adding projectiles to the inherent dangers
of the fire.
Immediate precautions to be taken in the event
of an accident or incident
Control or prevent fire. Remove tanks from vicinity of fire if safe to do
so.
Immediate methods for handling fires These tanks are not flammable, though their cardboard boxes are. Use
standard means for fighting paper fires.
Initial methods for handling spills or leaks in
the absence of fire
None. There is nothing to spill, and nitrogen and air mix with the
nitrogen and air in the vehicle, so a leak would be harmless unless a
charged tank were shipped by airfreight (which would have been
contrary to company policy).
Sta-Rite Industries, LLC 02-27-2011